Medicare Notice of Creditable Coverage – Deadline Looming
Employers who provide prescription coverage through either group medical or prescription plans should be aware that November 15th is the deadline for providing employees with a Medicare Notice of Creditable Coverage.
The purpose of the notice is to inform employees that their current prescription drug coverage (through their employer) pays out at least as much as the drug coverage offered through the 2009 Medical Prescription Drug Program. Therefore, their coverage is considered “creditable.”
Employers should take the following steps to ensure they are in compliance:
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Send the notice to all employees to ensure that employees -- and those who may have Medicare-eligible dependents on the plan -- are notified.
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E-mail this notification to employees, which is acceptable with the Centers for Medicare and Medicaid Services (CMS), if: 1) all employees have access to e-mail, and 2) it is also posted on the company website with a link from the home page.
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If notifying via email, the plan sponsor (employer) must inform the plan participant (employee) that the participant is responsible for providing a copy of the electronic disclosure to their Medicare-eligible dependents covered under the group health plan.
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Notify employees that there is no action necessary on their part if they, or their dependents, are not currently enrolled in Medicare A or B or are Medicare-eligible.
Employees must present this notice when preparing to enroll in Medicare Part D to avoid late enrollment penalties. Sample employee notices can be found on the Centers for Medicare and Medicaid Services (CMS) website.
In addition to the November 15 deadline, notice must also be provided when:
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The individual originally becomes eligible under the group plan;
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Upon a change in the plan’s creditable coverage status;
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Upon termination of the plan’s prescription drug benefit; and
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Upon an individual’s request
As a reminder, each plan sponsor (typically the employer) must also disclose to CMS their plans’ creditable coverage status annually within 60 days of the plan year via the CMS website. If you haven’t already notified CMS, we recommend that you do so at this time. Please visit the CMS website for guidance on how to notify employees, as well as how to report plan information to CMS. Organizations should also contact their benefits broker or benefits administrator to ensure compliance with this legislation.
Author: Lisa Denny, Senior HR Business Partner, Helios HR
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